interim final rule

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On June 1, 2026, Chief Judge Virginia Kendall of the U.S. District Court for the Northern District of Illinois issued a major follow-up opinion in Illinois Bankers Association v. Raoul that substantially alters the court’s February 2026 summary judgment decision regarding the Illinois Interchange Fee Prohibition Act (“IFPA”).

The new opinion was issued after the Seventh Circuit vacated the district court’s February ruling and remanded the case for reconsideration in light of the Office of the Comptroller of the Currency’s April 2026 Interim Final Rule and Interim Final Order addressing the IFPA.… Continue Reading

On February 5, 2024, several national and Texas banking and business trade groups (Plaintiffs) filed a lawsuit challenging the final regulations (Final Rules) implementing the Community Reinvestment Act of 1977 (CRA) that were jointly adopted in October 2023 by the Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, and Federal Reserve Board (Agencies).… Continue Reading

The CFPB has issued an interim final rule with a request for public comment on its new rules of practice for the issuance of temporary cease-and-desist orders (“Temporary C&Ds”). The Bureau is authorized to issue Temporary C&Ds under Section 1053(c) of the Dodd-Frank legislation. That provision, similar in many respects to the comparable provision in the Federal Deposit Insurance Act, authorizes a Temporary C&D as an adjunct to a cease-and-desist proceeding (the “case in chief”) brought under Section 1053(b) against a covered person or a service provider.… Continue Reading